BIS Updates Boycott Requester List

Commerce’s Bureau of Industry and Security (BIS) published its first quarterly update of the boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business.

The updated public list of entities who have been identified as having made a boycott-related request in reports received by BIS includes 57 additions. BIS has also removed 127 entities. The list is posted on the Office of Antiboycott Compliance (OAC) webpage link with the objective of helping U.S. persons comply with the reporting requirements of the antiboycott regulations set forth in Part 760 of the Export Administration Regulations (EAR), 15 CFR Parts 730-774.

Each entity on this list has been recently reported to BIS on a boycott request report form, as required by Section 760.5 of the EAR, as having made a boycott-related request in connection with a transaction in the interstate or foreign commerce of the United States. Those added to today’s updated list, which is not exhaustive, have been identified on the Requester List with “June 2024” in column C. A total of 127 parties have also been removed from the Requester List. BIS removed these parties, identified below, after being made aware that U.S. persons had misidentified a foreign party as having made a reportable boycott request or because the foreign party removed boycott language in transaction documents with U.S. entities. If you believe that you have been listed in error or would like to discuss a listing, please contact OAC. 

U.S. persons are encouraged to diligently review transaction documents from all sources, but especially transaction documents with or involving these listed parties – given that they have been identified by others as a source of boycott-related requests – to identify possible boycott-related language and to determine whether U.S.-person recipients have a reporting requirement to BIS pursuant to Part 760 of the EAR. The boycott request reporting form can be found here.